physical contact requirement (Wisconsin) · Go Syfert
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physical contact requirement in Wisconsin

8 Wisconsin opinions name it 2 courts 1983–2007 0 in the last five years

The cases below were cited by Wisconsin courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Hayne v. Progressive Northern Insurancegreen
wis · 1983 · cited in 5 Wisconsin opinions naming this issue, 1992–2007
2 sentences

2007Prior decisions explaining and interpreting the physical contact requirement are instructive to our determination in this case. ¶ 16 The first case in which we interpreted Wis. Stat. § 632.32 (4)(a)2.b. and established that the statute requires physical contact was Hayne, 115 Wis.2d at 69 , 339 N.W.2d 588 .

2007The court of appeals interpreted the physical contact requirement under Wis. Stat. § 632.32 (4)(a)2.b. to mean a " 'touching between the vehicles.'" Id. at 22 (quoting Hayne, 115 Wis. 2d at 78 ).

25
Smith v. General Casualty Insurancegreen
wis · 2000 · cited in 3 Wisconsin opinions naming this issue, 2005–2007
2 sentences

2007Id., ¶ 12, 619 N.W.2d 882 . ¶ 24 We relied on Hayne, Amidzich, and Wegner , which we classified as the cases in the "miss-and-run series," to explain the physical contact requirement.

2007In analyzing whether the chain-reaction type of collision in Smith met the physical contact requirement, we recognized that our decision in Theis was a "consideration of the public policy issues under-girding [uninsured] motorist coverage." Smith, 239 Wis. 2d 646, ¶ 24 .

13
Schultz v. Natwickgreen
wis · 2002 · cited in 1 Wisconsin opinions naming this issue, 2005–2005
2 sentences

2005We reject this argument because "no change in the law is justified simply by a `case with more egregious facts.'" Schultz, 257 Wis. 2d 19, ¶ 38 (quoting Stevens, 181 Wis. 2d at 442 (Abrahamson, J., concurring)).

2005We reject this argument because "no change in the law is justified simply by a 'case with more egregious facts.'" Schultz, 257 Wis. 2d 19, ¶ 38 (quoting Stevens, 181 Wis. 2d at 442 (Abrahamson, J., concurring)).

11
State v. Stevensgreen
wis · 1994 · cited in 1 Wisconsin opinions naming this issue, 2005–2005
2 sentences

2005We reject this argument because "no change in the law is justified simply by a `case with more egregious facts.'" Schultz, 257 Wis. 2d 19, ¶ 38 (quoting Stevens, 181 Wis. 2d at 442 (Abrahamson, J., concurring)).

2005We reject this argument because "no change in the law is justified simply by a 'case with more egregious facts.'" Schultz, 257 Wis. 2d 19, ¶ 38 (quoting Stevens, 181 Wis. 2d at 442 (Abrahamson, J., concurring)).

11
Simpson v. Farmers Insurancegreen
kan · 1979 · cited in 1 Wisconsin opinions naming this issue, 1983–1983
2 sentences

1983Co., Inc., 225 Kan. 508 , 592 P.2d 445, 449 (1979) (majority rule is that the physical contact requirement is contrary to public and legislative policy in uninsured or unknown motorist statutes); Surrey v. Lumbermens Mut.

1983Co., Inc., 225 Kan. 508 , 592 P.2d 445, 449 (1979) (majority rule is that the physical contact requirement is contrary to public and legislative policy in uninsured or unknown motorist statutes); Surrey v. Lumbermens Mut.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Wisconsin. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Theis v. Midwest Security Insurance green
wis · 2000
2 sentences

2007Id., ¶ 26 (quoting Theis, 232 Wis. 2d 749, ¶ 28 ). 10 Therefore, based on the language of the statute and the public policy concerns, we concluded the chain-reaction collision met the physical contact requirement for a "hit- and-run" and coverage was mandated under Wis. Stat. § 632.32 (4)(a)2.b.

2007Id., ¶ 26 (quoting Theis, 232 Wis. 2d 749, ¶ 28 ). 10 Therefore, based on the language of the statute and the public policy concerns, we concluded the chain-reaction collision met the physical contact requirement for a "hit- and-run" and coverage was mandated under Wis. Stat. § 632.32 (4)(a)2.b.

32000–2007
Wegner v. Heritage Mutual Insurance green
wisctapp · 1992
2 sentences

2007This reading would preserve the justification for the physical contact requirement, i.e., the prevention of *402 fraudulent claims." Id. at 127 , 496 N.W.2d 140 . ¶ 23 We once again interpreted Wis. Stat. § 632.32 (4)(a)2.b. in Smith , where the insured was driving his vehicle in the right lane of the interstate.

2007This reading would preserve the justification for the physical contact requirement, i.e., the prevention of *402 fraudulent claims." Id. at 127 , 496 N.W.2d 140 . ¶ 23 We once again interpreted Wis. Stat. § 632.32 (4)(a)2.b. in Smith , where the insured was driving his vehicle in the right lane of the interstate.

21999–2007
Dehnel v. State Farm Mutual Automobile Insurance green
wisctapp · 1999
1 sentence

2007The court of appeals interpreted the physical contact requirement under Wis. Stat. § 632.32 (4)(a)2.b. to mean a "`touching between the vehicles.'" Id. at 22 , 604 N.W.2d 575 (quoting Hayne, 115 Wis.2d at 78 , 339 N.W.2d 588 ).

12007–2007
Progressive Northern Insurance Company v. Romanshek green
wis · 2005
2 sentences

2007Id.

2007Id.

12007–2007
Bauman v. Gilbertson green
wis · 1959
2 sentences

2005"It is more than likely that some of the companies utilizing such [a clause] have established premium rates in reliance upon the validity of such a clause being upheld by the decisions of this court." Bauman v. Gilbertson, 7 Wis. 2d 467, 469 , 96 N.W.2d 854 (1959).

2005"It is more than likely that some of the companies utilizing such [a clause] have established premium rates in reliance upon the validity of such a clause being upheld by the decisions of this court." Bauman v. Gilbertson, 7 Wis. 2d 467, 469 , 96 N.W.2d 854 (1959).

12005–2005
Fandrey v. American Family Mutual Insurance green
wis · 2004
2 sentences

2005Co., 2004 WI 62, ¶ 16 , 272 Wis. 2d 46 , 680 N.W.2d 345 . 7 Therefore, as Hayne concluded that the physical contact requirement is part of the UM statute, it cannot contravene public policy; it is public policy. ¶ 61.

2005Co., 2004 WI 62, ¶ 16 , 272 Wis. 2d 46 , 680 N.W.2d 345 . 7 Therefore, as Hayne concluded that the physical contact requirement is part of the UM statute, it cannot contravene public policy; it is public policy. ¶ 61.

12005–2005
Patrick v. Head of the Lakes Cooperative Electric Ass'n green
wisctapp · 1980
1 sentence

2000Ass'n, 98 Wis. 2d 66, 69 , 259 N.W.2d 205 (Ct. App. 1980). 10 A number of courts and commentators have concluded that the physical contact requirement is designed to prevent drivers from claiming hit-and-run coverage after suffering accidents of their own making.

12000–2000
Amidzich v. Charter Oak Fire Insurance green
wis · 1969
2 sentences

2000Co., 44 Wis. 2d 45 , 170 N.W.2d 813 (1969), the first case setting forth the physical contact rule, an unidentified car forced the insured off the road; there was no physical contact between the cars. ¶ 23.

2000Co., 44 Wis. 2d 45 , 170 N.W.2d 813 (1969), the first case setting forth the physical contact rule, an unidentified car forced the insured off the road; there was no physical contact between the cars. ¶ 23.

12000–2000

Statutes the citing opinions construe

WI § Wis. Stat. § 632.32 (8) WI § Wis. Stat. § 346.67 (4) WI § Wis. Stat. § 802.08 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 16 (1978–2016) MI 16 (1978–2020) IL 12 (1986–2021) CA 10 (1967–2013) AZ 9 (1975–2006) KY 9 (1977–2005) WV 9 (1987–2022) WI 8 (1983–2007) LA 8 (1975–2003) PA 7 (1974–2021) TX 6 (1993–2008) IA 5 (1979–2012) AR 4 (1978–2007) ID 4 (1985–2011) NY 4 (1986–2007) CT 4 (1992–2018) NC 3 (2008–2017) SC 3 (1985–2010) MN 3 (1978–1989) MS 2 (1987–2002) TN 2 (1968–1983) NE 2 (1976–1989) MT 2 (1985–2011) VA 2 (1993–2015) SD 2 (1978–2012) DE 2 (1977–1978) MD 2 (1989–2007)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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